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AI Credit Scoring System

High-Risk

An AI system used by a bank to evaluate the creditworthiness of natural persons applying for consumer loans, using alternative data sources including transaction history and behavioural signals.

Classification Walkthrough

  1. Step 1 — Prohibited practices (Article 5): Credit scoring for loan decisions is not a prohibited practice (it differs from social scoring by public authorities). ✗ Not prohibited.
  2. Step 2 — GPAI: The system is a task-specific application, not a general-purpose AI model. ✗ Not GPAI.
  3. Step 3 — High-risk Pathway A: Not a safety component of an Annex I product. ✗ Not Annex I.
  4. Step 4 — High-risk Pathway B: Evaluating creditworthiness of natural persons falls under Annex III Category 5 (Access to and enjoyment of essential private and public services and benefits). ✓ Annex III Category 5.
  5. Step 5 — Conformity assessment: Self-assessment applies for essential services AI systems.
  6. Result: HIGH-RISK — The credit scoring system must comply with Articles 9-15 including risk management, data governance (with particular attention to bias in alternative data sources), technical documentation, transparency to deployers, and human oversight. Enforcement date: August 2, 2026.
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